<h2 mat-dialog-title>Privacy Policy</h2>

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    <p>This policy applies to all our all existing and new users as of 14th of April 2023.</p>

    <p>
        At AINIRO.IO, accessible from ainiro.io, one of our
        main priorities is our users privacy. This document contains types of information
        that is collected and recorded by AINIRO.IO and how we use it.
        This policy applies to all our all existing and new users as of 14th of April 2023.
    </p>

    <h2>SCOPE</h2>

    <p>
        AINIRO.IO AS (AINIRO.IO, "we") might collect and process personal data of users of
        AINIRO's
        website and online services. This Privacy Policy applies to personal data we obtain
        from our customers and their representatives (&ldquo;Users&rdquo;) through our websites
        when the relevant User registers to AINIRO's cloud-based infrastructure and software
        services (collectively, the &ldquo;Services&rdquo;). In addition, some of our services
        might be subject to a separate privacy policy. If a separate privacy policy applies to a
        particular service, we will post it on the relevant website or otherwise in connection
        with the service in question.
    </p>

    <p>
        Our Privacy Policy explains what data we process, how we do that and how the data subjects,
        i.e. Users, may use their rights (e.g. right to object, right of access).
    </p>

    <p>
        This Privacy Policy may be updated if required in order to reflect the changes in data
        processing practices or otherwise. The current version can be found on our website ainiro.io.
        We will not make substantial changes to this Privacy Policy or reduce the rights of Users
        under this Privacy Policy without providing a notice thereof.
    </p>

    <p>
        This Privacy Policy only covers data processing carried out by AINIRO.IO. The Privacy Policy
        does not address, and we are not responsible for, the privacy practices of any third parties.
        AINIRO.IO disclaims all responsibility for the processing carried out by third parties, also
        in cases where Services include hyperlinks to third parties' websites.
    </p>

    <p>
        Please note that this Privacy Policy applies to processing of personal data carried out by
        AINIRO.IO as a data controller. As regards the data AINIRO.IO's customers or Users insert
        into
        Services while using the Services, AINIRO.IO registers this personal data as a data processor
        and the relevant customer shall be considered to be the data controller with regard to this
        personal data.
    </p>

    <p>
        Privacy, security and online safety are important for us, and we process all personal data
        with due care and in accordance with applicable laws and regulations.
    </p>

    <h3>PERSONAL DATA PROCESSED AND SOURCES OF DATA.</h3>

    <p>
        We collect two types of information from the Users: (i) User Data; and (ii) Technical Data.
        Although we do not normally use Technical Data to identify individuals, sometimes individuals
        can be recognized from it, either alone or when combined or linked with User Data. In such
        situations, Technical Data can also be considered to be personal data under applicable laws
        and we will treat the combined data as personal data.
    </p>

    <p>
        AINIRO.IO may collect and process for example the following User Data from Users: (i) name and
        contact details; (ii) e-mail address; (iii) phone number; (iv) invoicing and billing information;
        (v) other personal data Users provide themselves.
    </p>

    <p>
        The specific kind of User Data collected will depend on the Services used by the User. Most of
        the User Data is received directly from Users at the point of registration or otherwise at
        beginning of and during the customer relationship.
    </p>

    <p>
        Technical Data we gather in connection with the use of our Services includes for example the
        following data: (i) User's IP address; (ii) browser type and version; (iii) preferred
        language; (iv) geographic location using IP address or the GPS, wireless, or Bluetooth
        technology on your device; (v) operating system and computer platform; (vi) the full Uniform
        Resource Locator (URL) clickstream to, through, and from our Services, including date and time;
        (vii) products or services User viewed or searched for while using our Services; and (viii)
        areas of our Services User has visited.
    </p>

    <h3>COOKIES</h3>

    <p>
        We use various technologies to collect and store Technical Data and other information when Users
        visit our Services, including cookies. Cookies allow us to calculate the aggregate number of
        people visiting our Services and monitor the use of the Services. This helps us to improve our
        Services and better serve our Users. We may also use cookies that make the use of the Services
        easier, for example by remembering usernames, passwords and preferences. We may use tracking
        and analytics cookies to see how well our Services are being received by our Users.
    </p>

    <p>
        Cookies are created and stored on the basis of the consent given by the user. The users give
        their consent through the pop-up window in upcloud.com and its subdomains.
    </p>

    <h3>WEB ANALYTICS SERVICES</h3>

    <p>
        Our Services use several web analytics services to compile Technical Data and reports on visitor
        usage and to help us improve our Services.
    </p>

    <h3>PURPOSES</h3>

    <p>
        There are several purposes for the processing of personal data by AINIRO.IO. Personal data is
        processed
        by AINIRO.IO for managing the relationships with customers, facilitating transactions and
        payments,
        and for managing, developing and analysing our customer service. Personal data is also used to
        direct marketing at special customer groups, and other business activities related to any of
        these activities.
    </p>

    <h3>
        Personal data is also processed by AINIRO.IO for the following purposes:
    </h3>

    <h4>TO PROVIDE OUR SERVICES AND CARRY OUT OUR CONTRACTUAL OBLIGATIONS.</h4>

    <p>
        We process personal data in the first place to be able to offer the Services to our customers
        and Users and to run, maintain and develop our business. In some cases, personal data may be
        processed in order to carry out our contractual obligations towards the User. We may use the
        data for example to offer essential functionalities of the Services and to provide access to
        the Services. If User contacts our customer service, we will use the provided information for
        answering questions and solving possible issues.
    </p>

    <h4>FOR CUSTOMER COMMUNICATION.</h4>

    <p>
        We may process personal data for the purpose of contacting Users regarding our Services and to
        inform Users of changes in our Services. Data may also be used for research and analysis
        purposes in order to improve our Services.
    </p>

    <h4>FOR QUALITY IMPROVEMENT AND TREND ANALYSIS.</h4>

    <p>
        We may process information regarding the use of the Services to improve the quality of our
        Services e.g. by analysing any trends in the use of our Services. When possible, we will do
        this using only aggregated, non- personally identifiable data.
    </p>

    <h4>LEGITIMATE GROUNDS FOR PROCESSING.</h4>

    <p>
        We process personal data to perform our contractual obligations towards Users and to comply
        with legal obligations. Furthermore, we process personal data to pursue our legitimate interest
        to run, maintain and develop our business.
    </p>

    <p>
        In some parts of the Services, Users may be requested to grant their consent for the processing
        of personal data. In this event, Users may withdraw their consent at any time.
    </p>

    <h4>TRANSFER TO COUNTRIES OUTSIDE OF EUROPE.</h4>

    <p>
        We store the Users' personal data primarily within the European Economic Area. However, we
        have service providers in several geographical locations. As such, we and our service providers
        may transfer personal data to, or access it in, jurisdictions outside the European Economic
        Area or the User's domicile.
    </p>

    <p>
        We will take steps to ensure that the Users' personal data receives an adequate level of protection
        in the jurisdictions in which it is processed. We provide adequate protection for the transfers
        of personal data to countries outside of the European Economic Area through a series of agreements
        with our service providers based on the Standard Contractual Clauses or other similar arrangements.
    </p>

    <p>
        More information regarding the transfers of personal data may be obtained by contacting us on
        addresses mentioned in this Privacy Policy.
    </p>

    <h3>RECIPIENTS</h3>

    <p>
        We only share personal data within the organisation of AINIRO.IO if and as far as reasonably
        necessary
        to perform and develop our Services. We do not share personal data with third parties outside of
        AINIRO.IO's organization unless one of the following circumstances applies:
    </p>

    <h4>IT IS NECESSARY FOR THE PURPOSES SET OUT IN THIS PRIVACY POLICY</h4>

    <p>
        To the extent that third parties need access to personal data to perform the Services, Arta
        Marketing has
        taken appropriate contractual and organisational measures to ensure that personal data are
        processed exclusively for the purposes specified in this Privacy Policy and in accordance with
        all applicable laws and regulations.
    </p>

    <h4>FOR LEGAL REASONS</h4>

    <p>
        We may share personal data with third parties outside AINIRO.IO's organization if we have a
        good-faith
        belief that access to and use of the personal data is reasonably necessary to: (i) meet any
        applicable
        law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security
        or technical issues; and/or (iii) protect the interests, properties or safety of AINIRO.IO, our
        Users
        or the public in accordance with the law. When possible, we will inform Users about such transfer
        and processing.
    </p>

    <h4>TO AUTHORIZED SERVICE PROVIDERS</h4>

    <p>
        We may share personal data to authorized service providers who perform services for us (including
        data storage, sales, marketing and customer support services). Our agreements with our service
        providers include commitments that the service providers agree to limit their use of personal
        data and to comply with privacy and security standards at least as stringent as the terms of this
        Privacy Policy. Please bear in mind that if you provide personal data directly to a third party,
        such as through a link on our website, the processing is typically based on their policies and
        standards.
    </p>

    <h4>FOR OTHER LEGITIMATE REASONS</h4>

    <p>
        If AINIRO.IO is involved in a merger, acquisition or asset sale, we may transfer personal data
        to the
        third party involved. However, we will continue to ensure the confidentiality of all personal data.
        We will give notice to all Users concerned when the personal data are transferred or become subject
        to a different privacy policy as soon as reasonably possible.
    </p>

    <h4>WITH EXPLICIT CONSENT</h4>

    <p>
        We may share personal data with third parties outside AINIRO.IO's organization for other
        reasons than
        the ones mentioned before, when we have the User's explicit consent to do so. The User has the
        right to withdraw this consent at all times.
    </p>

    <h4>STORAGE PERIOD</h4>

    <p>
        AINIRO.IO does not store personal data longer than is legally permitted and necessary for the
        purposes
        of providing the Services or the relevant parts thereof. The storage period depends on the nature
        of the information and the purposes of processing. The maximum period may therefore vary per use.
    </p>

    <p>
        Typically, we will store User's personal data for as long as the User or the relevant customer
        User represents is a registered subscriber or a registered user of our Services or for as long
        as we have another purpose to do so and, thereafter, for no longer than is required or permitted
        by law or reasonably necessary for internal reporting and reconciliation purposes.
    </p>

    <p>
        In general, personal data of Users are deleted within reasonable time after the User no longer
        uses any part of the Services or when the User makes a request regarding deletion of User's
        personal data.
    </p>

    <h4>USERS' RIGHTS</h4>

    <p>
        AINIRO.IO offers access for the Users to the personal data processed by AINIRO.IO. This
        means that
        Users may contact us and we will inform what personal data we have collected and processed
        regarding the said User and the purposes such data are used for.
    </p>

    <h4>RIGHT TO WITHDRAW CONSENT</h4>

    <p>
        In case the processing is based on a consent granted by User, User may withdraw the consent
        at any time. Withdrawing a consent may lead to fewer possibilities to use our Services.
    </p>

    <h4>RIGHT TO CORRECT</h4>

    <p>
        Users have the right to have incorrect, imprecise, incomplete, outdated, or unnecessary
        personal data we have stored about the User corrected or completed.
    </p>

    <h4>RIGHT TO DELETION</h4>

    <p>
        Users may also ask us to delete the User's personal data from our systems. We will comply
        with such request unless we have a legitimate ground to not delete the data. We may not
        immediately be able to delete all residual copies from our servers and backup systems after
        the active data have been deleted. Such copies shall be deleted as soon as reasonably possible.
    </p>

    <h4>RIGHT TO OBJECT</h4>

    <p>
        Users may object to certain use of personal data if such data are processed for other purposes
        than purposes necessary for the performance of our Services to the User or for compliance with
        a legal obligation.
    </p>

    <p>
        Users may also object any further processing of personal data after prior given consent. If
        User objects the further processing of personal data, this may lead to fewer possibilities
        to use our Services.
    </p>

    <p>
        In the event and at the sole discretion of AINIRO.IO, if it is determined that the Service can
        no
        longer be provided without customer acceptance of modified terms, a pro-rated refund of service
        will be paid back to the User.
    </p>

    <h4>RIGHT TO RESTRICTION OF PROCESSING</h4>

    <p>
        Users may request us to restrict certain processing of personal data, this may however lead
        to fewer possibilities to use our Services.
    </p>

    <h4>RIGHT TO DATA PORTABILITY.</h4>

    <p>
        Users have the right to receive their personal data from us in a structured and commonly used
        format and to independently transmit those data to a third party.
    </p>

    <h4>HOW TO USE THE RIGHTS</h4>

    <p>
        The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses
        set out above, including the following information: the full name, company name (if applicable),
        address, e-mail address and a phone number. We may request the provision of additional
        information necessary to confirm the identity of the User. We may reject requests that are
        unreasonably repetitive, excessive or manifestly unfounded.
    </p>

    <h4>DIRECT MARKETING</h4>

    <p>
        Notwithstanding any consent granted beforehand for the purposes of direct marketing, User has
        the right to prohibit us from using User's personal data for direct marketing purposes,
        market research and profiling by contacting us on the addresses indicated above or by using
        the functionalities of the Services or the unsubscribe possibility offered in connection with
        any direct marketing messages.
    </p>

    <p>
        You have the right to opt out of receiving electronic direct marketing communications from us,
        and choosing not to receive marketing communications from us in the future. AINIRO.IO uses the
        Users' e-mail addresses on record to communicate of updates and important information regarding
        the AINIRO.IO infrastructure in the form of occasional newsletters. Users have the possibility
        to
        opt out of these e-mails by unsubscribing through the e-mail itself.
    </p>

    <p>
        You also have the right to prohibit us from using your personal data for direct marketing purposes,
        market research and profiling by contacting us on the addresses indicated above. In case your
        personal data are processed based on your consent, you have the right to withdraw your consent
        for such processing.
    </p>

    <h4>LODGING A COMPLAINT</h4>

    <p>
        In case User considers our processing of personal data to be inconsistent with the applicable
        data protection laws, a complaint may be lodged with the local supervisory authority for data
        protection.
    </p>

    <h4>INFORMATION SECURITY</h4>

    <p>
        We will take all reasonable and appropriate security measures to protect the personal data
        we store and process from unauthorised access or unauthorised alteration, disclosure or
        destruction. Measures include for example, where appropriate, encryption, firewalls, secure
        facilities and access right systems.
    </p>

    <p>
        We maintain all personal data collected through industry standard safe mechanisms including,
        but necessarily limited to encryption of password data as well as API keys, SSL-encryption,
        passing of credit card information directly to our PCI compliant Merchant Processor and
        encryption of any collected credit card information.
    </p>

    <p>
        We use administrative, organizational, technical, and physical safeguards to protect the
        personal data we collect and process. Our security controls are designed to maintain an
        appropriate level of data confidentiality, integrity, and availability. We regularly test
        our websites, data centres, systems, and other assets for security vulnerabilities.
    </p>

    <p>
        Should despite of the security measures, a security breach occur that is likely to have
        negative effects to the privacy of Users, we will inform the relevant Users and other
        affected parties, as well as relevant authorities when required by applicable data protection
        laws, about the breach as soon as reasonably possible.

        Trade name: AINIRO.IO Ltd

        Mailing address: Afrodites 6, 7043 Larnaca, Cyprus

        Email: team@ainiro.io
    </p>

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